Ladies and Gentlemen:

Since we are talking anomolies in design guides, I take liberty and ask the
favor of your collective wisdom.  All input is considered valid, though I
particularly relish the thoughts of those in State Fire Marshals office and
more than a few building code inspectors, etc.

Speculation is welcome, but please attempt to rationalize your guess and
intentions.  I don't want to ask this on the IAFSS forum, it is rather
muted.  I don't want to ask this in LinkedIn, for reasons of separating
wheat from chaff.


Please bare in mind the political and economic climate of 2003 and the
contest that was fought in courts and in building departments between this
building code, and its North American rival...

2003 IBC Section 405.1  Exemption 3 (I think it still exists in 2015 IBC)
Fixed Guidway Transit Systems

Bare in mind that not even NFPA 5000 references NFPA 130 (Fixed Guideway
Transit Systems), and even though technically 2003 IBC does not reference
NFPA 130... there are not too many standards out there with the title
"Fixed Guideway Transit Systems"...so the framers of 2003 IBC were bold, if
not coy.

Question:  Why would the 2003 (and subsequent) IBC framers absolve their
regulatory responsibility for design of Metro stations deeper than 30 ft, *but
retain regulator responsibility *for design of Metro stations 30 ft and
shallower?

Was the 2003 IBC committee sending a message to the NFPA 130 committee that
its 50 words of sprinkler prescriptions (in a document of over 50,000 words
and numbers) simply was too 'arbitrary and capricous' for the IBC to work
with?  Its sprinkler prescriptions certainly are confusing and can be
interpreted as supporting either the most water-fearing HV electrical
engineeror the most sprinkler promoting NRC engineer.

The IBC has special regulations for buildings deeper than 30 ft, so the
answer to the above question is not "IBC is not capable or not willing to
deal with deep underground structures."  The 30 ft underground
line-in-the-sand comes from the BOCA antecedent of the IBC, but did BOCA
simply believe shallow Metro stations were safe enough for them to regulate?

It strikes me as difficult to believe that IBC simply "forgot" to absolve
itself of regulatory responsibility for Metro stations 30 ft and shallower.

NFPA 130 is a committee with many learned and wise people on it.  It is a
committee with very real and diverse philosophical and strategic viewpoints
however.  There are consultants whom I will not lump together, but whom
tend to the strategy of smoke control.  There has been a LOT of money made
on engineering smoke control systems for Metros.  And there are code
enforcers and emergency response team members whom tend to the strategy of
reliable exits and active fire protection.    Fortunately, a new wind is
blowing, and hopefully we will see active fire suppression prescribed
within the Metro cars, although the suppression industry tells me it is not
a profit market because the cars tend to be one-off designs for each city's
project.   Point is, active fire suppression in the location with a large
fuel load and shielding from platform sprinklers (i.e. cars), would greatly
reduce the fire risk in deep underground Metros...when we finally get that
codified.  Until then,  designers are left mystified as to why 2 different
design guides are needed (IBC and NFPA 101) for the same Metro project.
NFPA 101 takes the installation requirements for deep underground stations,
and IBC retains regulatory responsibility for the at-grade and elevated
stations.  The difference is not just semantics, because with firefighter
access elevators, gurneys, accessible means-of-egress, there are notable
differences.  Not to mention, NFPA 5000 and NFPA 101 simply don't deal with
haz-mat MAQ's with the finesse and authority IBC does.

So why would 2003 IBC absolve themselves of responsibility for design of
DUSs, but not Metro stations shallower than 30 ft?  What were they
thinking?  Each code change should have an "intent" statement attached to
it.  But then, fire and life safety consultants might lose a measureable
share of their business.

Sorry for my long letter, but my answer from the Building Code
representatives and NFPA committe members has been insightful, and I thank
them deeply for their time, but I still remain confused as to what the real
answer is and was.

Scot Deal
Excelsior Risk/Fire Engineering
gsm:  +420 722 141 478 (GMT + 1)
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